Transfer Pricing Services – Country by Country Reporting (CbCR) & BEPS Action 13 Compliance
SAJ Consulting – With the global push for tax transparency under the OECD BEPS framework, Country-by-Country Reporting has become a critical focus area for tax authorities worldwide. Errors, inconsistencies, or late filings in CbCR can trigger audit risks, penalties, and increased scrutiny across multiple jurisdictions. Ensuring accurate and compliant CbCR is therefore essential for multinational enterprise (MNE) groups.
Country-by-Country Reporting, introduced under OECD BEPS Action 13, requires MNE groups to disclose key financial and operational information for each tax jurisdiction in which they operate. This includes revenue, profit or loss before tax, income taxes paid and accrued, stated capital, retained earnings, number of employees, and tangible assets. The primary objective is to provide tax authorities with a high-level risk assessment tool to evaluate whether profits are aligned with economic activities.
CbCR compliance involves more than simply compiling data. A critical step is the consolidation and validation of group-wide financial and operational information sourced from multiple entities and systems. This process requires careful reconciliation to ensure data accuracy, consistency, and alignment with group financial statements. Robust internal controls and clear data governance are essential to minimize reporting risks.
SAJ Consulting – Transfer Pricing Services
Equally important is ensuring consistency between the CbCR, Master File, and Local File documentation. Discrepancies across these documents may raise red flags for tax authorities and increase the likelihood of transfer pricing audits. Consistency checks help ensure that the group’s value chain, transfer pricing policies, and reported financial outcomes present a coherent and defensible narrative.
In addition, MNE groups must comply with local CbCR filing, notification, and exchange-of-information requirements. This includes determining the appropriate reporting entity, managing surrogate filing arrangements where applicable, and meeting jurisdiction-specific deadlines.
By managing CbCR obligations in line with OECD BEPS Action 13, MNE groups can enhance transparency, reduce compliance risks, and better prepare for tax authority scrutiny.
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Strengthen your CbCR compliance and reduce global tax risk. Engage experienced advisors to ensure accurate reporting, document consistency, and full alignment with OECD BEPS Action 13 requirements.
